Alexander v. Commissioner

OPINION.

Disney, Judge-.

1. The Commissioner in the deficiency notice increased petitioner’s reported taxable income for 1939, 1940, and 1941, (so far as herein concerned) by adding thereto $10,385.14, $12,220.54, and $11,413.42, respectively. It is stated in the notice of deficiency that these amounts represent one-fourth of the net income disclosed on the partnership return of Alexander Brothers Baking Co. and shown thereon as distributable income to Helen Alexander or Helen Alexander trust. The Commissioner held that such income was taxable to petitioner under section 22 (a), or under…